1. PRELIMINARY DETERMINATION. ANALYSIS AND PRELIMINARY DETERMINATION FOR THE CONS TRUCTION AND

OPERATION PERMITS FOR THE PROPOSED MODIFICATION

OF TWO DIESEL ELECTRIC GENERATORS

FOR CITY CENTER WEST, TO BE LOCATED AT 525 JUNCTION ROAD, MADISON, DANE COUNTY, WISCONSIN

Permit # 07-POY-022 and 113225200-F01 Facility ID # 113225200

This review was performed by the Wisconsin Departme nt of Natural Resources, Bureau of Air Management in accordance with Chapter 285, Wis. Sta ts., and Sections NR 400 to NR 499, Wis. Adm. Code.

Reviewed by: Paul Yeung Date:3/12/2007

Peer review conducted by: /s/ POY for Susan Lindem Date:3/12/20 07

Preliminary Determination Approved by: Signature Da te
Regional Supervisor or Central Office Designee: /s/ Thomas Roushar 3/12/2007

Stationary Source Modeling Team Leader: /s/ John A Roth 3/12/2007

Compliance Engineer (reviewed/approved): /s/ POY f or Ron Daggett 3/12/2007

cc: Ronald Daggett — South Central Region Dane County Library Service, 201 W. Mifflin St., Ma dison, WI 53703-25972. Introduction

INTRODUCTION

Stationary sources that are not specifically exempt from the requirement to obtain a construction perm it under s. 285.60(5), Wis. Stats. or ch. NR 406, Wis. Adm. Code may not commence construction, reconstruction, replacement, relocation or modifica tion unless a construction permit for the project h as been issued by the Department of Natural Resource’s (DNR’s) Air Management Program. Owners or operators subject to the construction permit requir ements must submit a construction and operation per mit application to the DNR. The application is reviewed following the provisions set forth in ss. 285.60 t o 285.65, Wis. Stats. The criteria for permit issuanc e vary depending on whether the source is major or minor and whether the source is locating in an atta inment or nonattainment area.

Subject sources are to be reviewed with respect to the equipment and facility description provided in the application and for the resulting impact upon the a ir quality. The review ensures compliance with all applicable rules and statutory requirements. The pl an review will show why the source(s) should be approved, conditionally approved, or disapproved. I t will encompass emission calculations and an air quality analysis using US EPA models, if applicable . As a precautionary note, the emission estimates a re based on US EPA emission factors (AP-42) or theoret ical data and can vary from actual stack test data.

The sources included in this construction permit ar e also required to obtain an operation permit under s. 285.60(1)(b), Wis. Stats. This review constitutes t he Department’s review of applications for both the construction permit and the operation permit for th ese units. This review may be updated when the compliance demonstration information is received. A n operation permit may be issued after the applican t demonstrates that the sources included in the const ruction permit are in compliance with the applicabl e rules, emission limits and the conditions. Completi on of this project will also result in a revision o f the facility-wide operation permit. Once construction i s complete and compliance with applicable requirements has been demonstrated, a revised facil ity-wide operation permit may be issued which incorporates the requirements of the construction p ermit. This preliminary determination also addresse s the development of the revised facility-wide operat ion permit.

3. General Application Information GENERAL APPLICATION INFORMATION

Owner/Operator: City Center West 525 Junction Road Madison, WI 53707

Responsible Official: John Kothe, VP Operations 608-663-7652

Application Contact Person: Scott A Tebon, Construc tion Project Mgr 608-663-7657

Application Submitted By: Scott A Tebon, Constructi on Project Mgr 608-663-7657

Application submittal date: 01/29/2007

Additional Information Submitted: January 29, 2007, February 1, 2007, February 5, 2007 and March 2, 2007

Date of Complete Application: March 2, 2007

4. Project Description PROJECT DESCRIPTION

The company owns the commercial properties at the l ocation. There are two emergency electricgenerators on site, installed under the exemption u nder s. NR 406.04(1)(w), Wis. Adm. Code. The

company is proposing to modify these generators suc h that they will be allow to provide electric power to the grid, thus making these peak shaving generators

.
The maximum theoretical emissions of criteria pollu tants from these two generators combined exceed the thresholds given in s. NR 406.04(2), Wis. Adm. Code . Thus a construction permit and an operation permit will be required.

5. Source Description SOURCE DESCRIPTION

Description of New or Modified Units.

The two generators are both Detroit Diesel Generato rs Model 16V4000 with 2935 bhp and 2189 KW stand-by generation power. According to the manufa cturer the maximum fuel usage is 0.326 pound per bhp-hour. The maximum heat input is 19.6 million BT U per hour. The maximum diesel fuel usage is 135 gallons per hour. The maximum sulfur content of th e diesel oil is 15 ppm. These were installed as emergency electric generators under the specific ex emption at 525 Junction Road was installed in 2001 (P01, S01) and the one at 535 Junction Road was ins talled in 2003 (P02, S02).

There is another small emergency generator (P03, S0 3). This is a Detroit Diesel Generator Model 150DSEJB with 160 KW maximum power. It was install ed at the parking ramp of the commercial property complex.

Stack Parameter Summary.

Stack ID Circular or

Rectangular Dis charge

Direction Exhaust

Obstacle Diameter or

Width (if rect.) Length (if

rect.) Height Temp. Normal Flow Rate Maximum

Flow Rate U, D, H True/False ft (m) ft (m) ft (m) ° F ACFM ACFM S01 C U FALSE 1.33 14 837 22116 22116 S02 C U FALSE 1.33 45 837 221 16 22116

Insignificant Emissions Units.

Boiler, Turbine, and HVAC System Maintenance. Convenience Space Heating (< 5 million BTU/hr Burni ng Gas, Liquid, or Wood). Convenience Water Heating. Fire Control Equipment. Janitorial Activities. Maintenance of Grounds, Equipment, and Buildings (l awn care, painting, etc.). Office Activities. Sanitary Sewer and Plumbing Venting.

6. Cross Media Impacts CROSS MEDIA IMPACTS

No cross media impact is expected from the project.7. Emission Calculations

EMISSION CALCULATIONS.

Particulate Matter (PM)

The company provided that the emission performance data from the generator manufacturer. The PM maximum emission is 294 grams per hour, thus the ma ximum PM emissions will be:

294 g/hr / 453.6 g/# = 0.65 #/hr

The applicable emission limit as given by s. NR 485 .055, Wis. Adm. Code is 0.5 pound per million BTU. The hourly allowable emission rate will then be:

19.6 mmbtu/hr x 0.5 #/mmbtu = 9.8 #/hr

However, computer modelling results showed that the ambient air particulate matter impact will exceed the allowable increment. The company proposed a PM emission limit of 1.35 pound per hour. At that emission rate the PM will be:

1.35 #/hr / 19.6 mmbtu/hr = 0.069 #/mmbtu.

Annual PM potential to emit will be, based on the 2 00 hours/yr limit:

200 hr/yr x 1.35 #/hr / 2000 #/ton = 0.14 ton/yr

Both generators: 2 * 0.14 ton/yr = 0.28 ton/yr

Sulfur Dioxide (SO 2 )

The maximum fuel usage is 0.326 #/bhp-hr, at rated 2935 bhp, the maximum fuel usageis:

0.326 #/bhp-hr * 2935 bhp = 956.81 #/hr

The maximum sulfur content is 15 ppm (0.0015%). Ea ch pound of sulfur will produce a maximum of 2 pounds of SO 2 emissions. Thus the maximum SO 2 emissions will be:

2 * 956.81 * 15E-6 #/hr = 0.029 #/hr

Annual SO 2 potential to emit will be, based on the 200 hours/ yr limit:

200 hr/yr x 0.029 #/hr / 2000 #/ton = 0.003 ton/yr

Both generators: 2 * 0.003 ton/yr = 0.006 ton/yr

Nitrogen Oxides (NO x )

NO x The generator will meet the Tier 1 requirement for NO x of 6.9 g/bhp-hr

6.9 g/bhp-hr * 2935 bhp / 453.6 g/# = 44.65 #/hr

Annual NO x potential to emit will be, based on the 200 hours/ yr limit:

200 hr/yr x 44.65 #/hr / 2000 #/ton = 4.47 tons/yrBoth generators: 2 * 4.47 tons/yr = 8.94 tons/yr

Carbon Monoxide (CO)

CO The generator will meet the Tier 1 requirement f or CO of 8.5 g/bhp-hr

8.5 g/bhp-hr * 2935 bhp / 453.6 g/# = 55 #/hr

Annual CO potential to emit will be:

200 hr/yr x 55 #/hr / 2000 #/ton = 5.5 tons/yr

Both generators: 2 * 5.5 tons/yr = 11.0 tons/yr

Volatile Organic Compound (VOC)

VOC The generator will meet the Tier 1 requirement for VOC of 1.0 g/bhp-hr

1.0 g/bhp-hr * 2935 bhp / 453.6 g/# = 6.47 #/hr

Annual VOC potential to emit will be, based on the 200 hours/yr limit:

200 hr/yr x 6.47 #/hr / 2000 #/ton = 0.65 ton/yr

Both generators: 2 * 0.65 ton/yr = 1.3 tons/yr

The total HAP emission factor from diesel generator sets is given in Tables 3.4-3 and 3.4-4 in AP-42 b y USEPA as 4.364 x 10 -3 #/mmbtu. Maximum heat input for each generator wi ll be 19.6 mmbtu/hr. Total HAP from each generator will be:

4.364 x 10 -3 #/mmbtu x 19.6 mmbtu/hr = 0.086 #/hr

0.086 #/hr * 200 hr/yr / 2000 #/ton = 0.0086 tons/y r

With both sets together, the total HAP emissions wi ll be:

0.086 #/hr x 2 = 0.172 #/hr 0.0086 ton/yr x 2 = 0.017 ton/yr

8. Wisconsin Hazardous Air Pollutant (NR 445) Review WISCONSIN HAZARDOUS AIR POLLUTANT (NR 445) REVIEW

The use of diesel oil as fuel in electric generator s will result in some amounts of hazardous air poll utants (HAPs) emissions. Diesel oil is a distillate fuel o il which is a Group 1 virgin fossil fuel. Combusti on of Group 1 virgin fossil fuels is exempt from the Emis sion Thresholds, Standards & Control Requirements listed in Table A, s. NR445.07; Wis. Adm. Code, how ever, CI engines are subject to the Fuel, Control & Compliance Requirements of s. NR445.09, Wis. Adm. C ode.

The federal HAP emissions will be less than 0.1 ton per year based on potential to emit.9. Compliance and Technology Review

COMPLIANCE AND TECHNOLOGY REVIEW

The generator set will emit criteria pollutants due to the internal combustion of #2 diesel fuel oil. The generator/engine set will have a PM emission limit of 1.35 pounds per hour. This emission limit is necessary to prevent any exceedance of the PM ambie nt air standard and increment consumption limit. According to the emissions data provided by the eng ine manufacturer, this PM emission limit should be met. The worst case PM emission rate is expected t o be 0.65 pound per hour.

The company proposed to limit the electricity outpu t to 200-hrs per year. This will result in less th an 100 tons per year for each of the criteria pollutants. No environmental assessment will be necessary. To demonstrate compliance with this limit, the company proposed to keep monthly records on hours of operation for each generator.

The company also proposed to limit the amount of di esel fuel burned to less than 10,000 gallons per an y 12 consecutive months for each generator. This wil l result in the avoidance of the applicability of s . NR 445.09(3), Wis. Adm. Code. The two engines/generat ors will still be subject to the fuel requirement i n s. NR 445.09(2), Wis. Adm. Code and will only combust fuel oil with a sulfur content no greater than the sulfur content that is allowed for on-road use at t he time the fuel was purchased, when firing the eng ine with fuel oil.

To demonstrate compliance with this limit, the comp any will keep monthly records on the gallons of fue l purchased each generator.

10. Air Quality Review AIR QUALITY REVIEW

Mrs. Gail Good has performed the air quality review for the project, the following are her finding and conclusion.

II. MODEL RESULTS

The results demonstrate that the ambient air qualit y standards for TSP, PM 10 , SO 2 , CO, and NO x will be attained and maintained assuming the emission rates and stack pa rameters listed in the attached source table.

Modeling Analysis Results (All Concentrations in μ g/m 3 ) 1.

TSP – 24 hr PM 10 – 24 hr PM 10 – Annual

Modeled Concentration 29.9 29.9 9.7

Increment - 30.0 17.0

%Increment Consumed - 99.7 57.1
Background Concentration 69.3 56.0 22.2

Total Concentration 99.2 85.9 31.9
NAAQS 150.0 150.0 50.0
% NAAQS 66.1 57.3 63.8Modeling Analysis Results (All Concentrations in μ g/m 3 ) 2.

SO 2 – 3 hr SO 2 – 24 hr SO 2 – Annual

Modeled Concentration 30.3 6.7 0.45

Increment 512.0 91.0 20.0

% Increment Consumed 5.9 7.4 2.3
Background 128.3 33.5 7.9

Total Concentration 158.6 40.2 8.4
NAAQS 1300.0 365.0 80.0
% NAAQS 12.2 11.0 10.5

Modeling Analysis Results (All Concentrations in μ g/m 3 ) 3.

CO – 1 hr CO – 8 hr NO x – Annual

Modeled Concentration 3575.3 1510.4 6.7

Increment - - 25.0

% Increment Consumed - - 26.8 Background Concentration 3188.0 890.4 13.6

Total Concentration 6763.3 2400.8 20.3
NAAQS 40000.0 10000.0 100.0
% NAAQS 16.9 24.0 20.3

D. CONCLUSION

The results of the modeling analysis demonstrate th at the applicable air quality standards will be sat isfied assuming the emissions rates and stack parameters listed in the source table. Note that the generators at City Center West will be limited to 200 hours of operation per year.

City Center West - Madison Stack Parameters

ID LOCATION

(UTM – NAD27) HEIGHT (M) DIAM

(M) VELOCITY

(M/S) TEMP

(K)

S1 294515, 4771961 4.27 0.41 80.9 720.2
S2 294464, 4771974 13.72 0.41 80.8 720.2
S3 294524, 4771960 2.44 0.10 70.4 838.6
DEAN 294764, 4772289 3.35 0.36 63.6 760.8City Center West - Madison Emission Rates

ID PM (#/HR) SO2 (#/HR) CO (#/HR) NOx (#/HR)*

S1 1.352 0.014 54.7 44.36 (1.01)

S2 1.352 0.014 54.7 44.36 (1.01)

S3 0.22 - 4.7 3.79 (0.09)

DEAN 0.65 - - 9.25

* The generators are limited to 200 hours per year in order to get passing NOx results. The NOx emiss ion rates were scaled accordingly. The rate is shown first w ith the scaled rate, used in the modeling, shown se cond.

4. Emissions From New Equipment or Modification EMISSIONS FROM NEW EQUIPMENT OR MODIFICATION

A. Stack Emissions.

I. P01, S01 and P02, S02, each

Potential to Emit

Pollutant Pounds per Hour (lbs/hr) Tons per Year

(TPY)

Particulate matter (PM) 1.35 0.14

Sulfur dioxide (SO 2 ) 0.029 0.003

Nitrogen oxides (NO x ) 44.65 4.47

Carbon monoxide (CO) 55.0 5.5

Volatile organic compounds (VOCs) 6.47 0.65

5. Total Emissions From New Equipment or Modification TOTAL EMISSIONS FROM NEW EQUIPMENT OR MODIFICATION

Pollutant Potential to Emit (TPY unless otherwise noted)

Particulate matter (PM) 0.28

Sulfur dioxide (SO 2 ) 0.006Nitrogen oxides (NO x ) 8.94

Carbon monoxide (CO) 11.0

Volatile organic compounds (VOCs) 1.3

Total Federal HAPs (s. 112(b) pollutants) < 10

6. Facility and Project Classification FACILITY AND PROJECT CLASSIFICATION

1. Existing Facility Status.

Currently, there are only three generators on site and they were all installed as emergency generators

, based on the exemption in s. NR 406.04(1)(w), Wis. Adm. Code. By definition, they are limited to less than 200 hours per year. As such, the facilit y is a minor source for PSD, Part 70 and HAPs.

2. Project Status.

The company proposed to have the two larger generat ors to be peak shaving generators, but still proposed to be limited to 200 hours of operations. Thus, the project will result in the facility remaining as a minor source for PSD, Part 70 and HA Ps.

3. Facility Status after Completion of the Project.

The company proposed to have the two larger generat ors to be peak shaving generators, but still proposed to be limited to 200 hours of operations. Thus, the project will result in the facility remaining as a minor source for PSD, Part 70 and HA Ps.

4. Summary.

NSR Applicability Existing Facility Proposed Project Facility After Project Major Minor Major Minor Major Minor

PSD X X

Non-Attainment NA

Federal HAP X X X

Part 70 Applicability Existing Facility Facility After Project
Part 70 FESOP (Syn. Minor) non - part 70 Part 70 FESOP (Syn. Minor) non - part 70

Status X X

7. Environmental Analysis ENVIRONMENTAL ANALYSIS

The proposed project is a Type III action under Cha pter NR 150, Wis. Adm. Code, because there is a potential increase in hazardous emissions and the p otential to emit of the project is less than 100 TP Y for each criteria pollutant.A news release is required for this proposal and is included in the public comment notice. It is propo sed

that an environmental assessment not be completed.

8. Rule Applicability RULE APPLICABILITY

There is an NSPS subpart IIII promulgated on July 1 1, 2006 for compression ignition engines. The firs t model year subject to the NSPS will be 2007. These generators were installed prior to 2004. The NSPS covers engines that have been modified. These gene rators will become peak shaving generators and thus there will be a change in mode of operation. Howev er, there will not be any increase of emissions, th us it is not a modification under NSPS.

The generators are subject to the particulate matte r emission limit of 0.5 pound per million heat inpu t as given in s. NR 485.055, Wis. Adm. Code. However, a t that emission rate the ambient air standard will be exceeded. To protect the ambient air standard, the applicant has proposed an emission limit of 1.35 pound per hour for each generator.

NR 485.05(4), Wis. Adm. Code states that the visibl e emission limit for semistationary diesel engines is 40% opacity for no more than 5 minutes in any 30-mi nute period. However, these are stationary engines producing electric power, not semistationary genera tors such as those in construction sites. Therefor e, NR 431.05, Wis. Adm. Code with visible emission lim it of 20% opacity will be applicable.

The proposed project will result in the potential t o emit of each criteria pollutant of less than 100 tons per year. There will be federally enforceable permit conditions in place in order to limit the potential to emit. The total potential to emit of federal hazardous ai r pollutants (HAPs) from the project will be less t han 10 tons per year. The proposed facility will be a syn thetic minor source for PSD, Part 70 and the feder al HAP program.

The company proposes to limit the use of diesel fue l to less than 10,000 gallons per year for each generator, thus avoiding the applicability of s. NR 445.09(3), Wis. Adm. Code. The two engines/generators will still be subject to the fue l requirement in s. NR 445.09(2), Wis. Adm. Code an d will only combust fuel oil with a sulfur content no greater than the sulfur content that is allowed fo r onroad use at the time the fuel was purchased, when f iring the engine with fuel oil.

9. New Source Performance Standards (NSPS) Applicabili ty NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILI TY

For proposed construction of a source:

1. Is the proposed source in a source category for wh ich there is an existing or proposed NSPS? Yes

No Not applicable. (If yes, identify the source catego ry.)

2. Is the proposed source an affected facility? Yes No Not applicable. (Explain if necessary to clarify.)

For the proposed modification of an existing source :

1. Is the existing source, which is being modified, in a source category for which there is an existing o r proposed NSPS? Yes No Not applicable. (If yes, identify the source catego ry.) There is an NSPS subpart IIII promulgated on July 11, 2006 f or compression iginition engines. The first model year subject to the NSPS will be 2007. These generators were installed prior to 2004. The NSPS covers engines that have been modified. These generators will become peak shaving generators and thus there will be a change in mode of operation. However, there will not be any increase of emissions, thus it is not a modificatio n under NSPS.2. Is the existing source, which is being modified, an affected facility (prior to modification)? No

3. Does the proposed modification constitute a modific ation under NSPS to the existing source? No

4. Will the existing source be an affected facility af ter modification? No

10. National Emission Standards For Hazardous Air Pollu tants (NESHAPS) Applicability NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLU TANTS (NESHAPS) APPLICABILITY

Part 61 NESHAPS:

1. Will the proposed new or modified source emit a pol lutant controlled under an existing or proposed NESHAPS? Yes No (if yes, identify the pollutant).

2. Is the proposed new or modified source subject to a n existing or proposed NESHAPS? Yes No (if yes, identify NESHAPS).

Part 63 NESHAPS:

1. Will the proposed new or modified source emit a pol lutant controlled under an existing Part 63 NESHAPS? Yes No (if yes, identify the pollutant). Formaldehyde

2. Is the proposed new or modified source subject to a n existing Part 63 NESHAPS? Yes No (if yes, identify NESHAPS).

3. Is the proposed project subject to s. 112(g) of the Clean Air Act? Yes No.

The section 112(g) rules only apply to case-by-case MACT standards that are developed for new construction or reconstruction of sources that (by themselves) constitutes a new major source of federal hazardous air pollutants (for source catego ries not covered under an existing Part 63 MACT standard).

11. Criteria For Permit Approval CRITERIA FOR PERMIT APPROVAL

Section 285.63, Wis. Stats., sets forth the specifi c language for permit approval criteria. The Depart ment finds that:

1. The source will meet emission limitations.

2. The source will not cause nor exacerbate a violatio n of an air quality standard or ambient air increment.

3. The source is operating or seeks to operate under a n emission reduction option. Not Applicable.

4. The source will not preclude the construction or op eration of another source for which an air pollutio n control permit application has been received.

12. Determination DETERMINATION

The preliminary determination of the DNR Air Manage ment Program is that this project when constructed or modified and operated consistent wit h the application and subsequent informationsubmitted will be able to meet the emission limits and conditions included in the attached Draft Permi t. A

final decision regarding emission limits and condit ions will be made after the Department has reviewed and evaluated all comments received during the comm ent period. The proposed emission limits and other proposed conditions in the Draft Permit are written in the same form that they will appear in the construction permit and, where applicable, the oper ation permit. These proposed conditions may be changed as a result of public comments or further e valuation by the Department.13. Permit Fee Calculation

CONSTRUCTION PERMIT FEE CALCULATION

Basic Fees.

1. Construction or replacement of a PSD or NAA minor s ource or the PSD or NAA minor modification of a Part 70 minor so urce. [$2,300] $2300

Total Basic Fees $2300

Additional Fees.

2. The application is for a source not reviewed under ch. NR 405 or 408, Wis. Adm. Code, where the applicant requested in writing and received the permit in 50 days or less. [$2,650] 1 × $2650 $2650

3. The application is for a source which requires spec ific permit conditions to limit the facility potential to emit in order to make the source or modification a PSD, NAA or Part 70 minor source or a PSD or NAA minor modification. [$2,150] 1 × $2150 $2150

4. The permit application required the review and anal ysis of 2 basic emissions unit(s). [$400 per basic emission unit, 2 basic emissions unit(s).] 2 × $400 $800

5. The permit application is for a PSD or NAA minor so urce or minor modification to a major PSD or NAA source whose pro jected air quality impact requires a detailed air quality mode ling analysis. [$700] 1 × $700 $700

Total Additional Fee $6300

Total Fee (Total Basic Fee + Total Additional Fee) $8600

Credit(s).

6. The initial fee submitted with the application. [$1 ,350 or $1,000 if the application was received before July 1, 2000] ($1350)

7. The applicant publishes the newspaper notice. [$150 ] ($150)

Total Credit ($1500)

TOTAL AMOUNT DUE (Total Fee + Total Credit) $7100